Draft CY03 WRAP Work PlanOctober 22, 2002

DRAFT

Western Regional Air Partnership

2003 Work Plan

October 22, 2002

Table of Contents

Executive Summary...... …………………………………… ES-1

I.Overview………………………………………………………………………………. 1

II.Background...... ……………………….. 1

III.Tribal Options for Implementation Plan Development...... ………………………. 2

IV.WRAP Organization and Structure...... ……………………….. 2

  1. Membership...... ………………………………………….. 3
  2. Charter and Bylaws...... …………………………………... 3
  3. WRAP Organization...... …………………………………. 3
  4. Coordinating Group...... ………………………………….. 3
  5. Oversight Committees (Initiatives and Technical)………………………………… 4
  6. Communications Committee...... ………………………… 4
  7. Stakeholder Involvement...... …………………………….. 4

V.Project Management...... ……………………………………… 5

  1. Setting Priorities...... ……………………………………… 5
  2. Reconciling Conflicts...... ………………………………… 5
  3. Outreach and Peer Review...... …………………………… 6
  4. State and Tribal Coordination...... ………………………… 6
  5. Administration and Staffing...... ………………………….. 6
  6. Contract Management...... ………………………………… 8

VI.Regional Haze Work Plan...... ………………………………… 9

A.Market Trading Forum...... ……………………………….. 9

B.Fire Emissions Joint Forum...... ………………………….. 13

C.Air Pollution Prevention Forum...... ……………………… 15

D.Mobile Source Forum...... ………………………………… 17

E.Sources In and Near Class I Areas Forum...... ………………………. 20

F.Economic Analysis Forum...... …………………………… 22

G.Air Quality Modeling Forum...... ………………………… 24

H.Emission Forum...... ……………………………………… 27

I.Tribal Data Development Work Group...... ………………. 30

J.Research and Development Forum...... ………………….. 32

K.Ambient Monitoring and Reporting Forum...... ………….. 35

L.Air Managers Committee...... ……………………………. 37

M.Communications Committee...... ………………………… 39

Appendix A: Preliminary Long-Term Budget

Appendix B: Market Trading Forum Work Plan

Appendix C: Preliminary 2004-05 Work Plan for the Fire Emissions Joint Forum

Draft CY03 WRAP Work PlanOctober 22, 2002

EXECUTIVE SUMMARY

The WRAP is reaching a turning point in 2003. Most major technical and policy products needed for Section309 SIPs have been completed, products for Section308 SIPs must now be more directly addressed, and these products must complement the longer term (i.e., 2008) needs for Section309SIP revisions. As the WRAP turns its attention to longer term and Section 308 requirements, its planning process is made more complicated by the recent decision of the U.S. Court of Appeals for the District of Columbia Circuit in the case of the American Corn Growers Association versus the U.S. Environmental Protection Agency. This decision creates more uncertainty as to how states will determine which BART-eligible sources should be subject to BART and how the visibility benefits of BART should be determined. It also raises uncertainty about when §308SIPs will be due, which may be earlier than originally planned by some states. Finally, the state of Alaska has joined the WRAP, which adds considerable complexity through additional data and analytical requirements and the consideration of another 200 tribes. A map of the WRAP region and its members is shown in Figure1.

All major WRAP products needed for §309 SIPs should be completed by the end of 2002. Many of these products, the efforts behind them, and the knowledge garnered from them will also benefit the §308 SIP development process. A summary of the major §309 products is shown in Table1. Activities and projects planned for 2003 fall into three categories: (1) miscellaneous products needed to complete the §309 SIPs but not necessarily critical to making decisions on §309 SIP submittals or the strategies therein; (2) new projects and extensions of existing projects intended to support §308 SIPs and the longer-term needs of §309 SIPs; and (3) efforts needed to evaluate haze and develop a SIP for Alaska. Major activities in each of these categories are summarized in Tables2, 3, and4. A list of all the activities to be funded by the grant for this work plan is provided in the budget in Table5. (Note, many activities conducted by the WRAP do not appear as line items but are included within staff salaries or provided in-kind through member participation.)

A long-term conceptual schedule for WRAP activities is shown in Table6. The schedule assumes that §308SIPs would be due by the end of 2007. This end date is based on recent indications by EPA intended to promulgate health-based PM2.5 SIPs as soon as possible while providing the maximum opportunity to harmonize their development with regional haze SIPs.

Some organizational changes within the WRAP since the last work plan update include the addition of Alaska, the addition of a Dust Emissions Joint Forum, the transition of the Mobile Sources Joint Forum to the Mobile Sources Forum (now a policy forum under the Initiatives Oversight Committee), and the transition of the Northern Air Managers Committee to the Air Managers Committee (which now includes state and tribal air directors from the entire WRAP region). Finally, a work group has been formed under the Air Managers Committee called the STIP-II Work Group comprised of SIP writers to update the state and tribal implementation plan templates and perform other work needed to ensure that WRAP products and services are as helpful as possible to the process of adopting §309SIPs and TIPs. Many of these changes are shown in the organizational chart in Figure2.

Four full time staff members have been added to facilitate WRAP activities. The first position assists the state caucus of the Air Managers Committee, the second assists the tribal caucus of the Air Managers Committee, the third assists the Technical Oversight Committee and its associated forums, and the fourth assists the Initiatives Oversight Committee and its associated forums.

Finally, the WRAP Web site is being updated to accommodate the growing number of WRAP products and interested parties, including the general public. The new Web site will be more consistent with modern-day design standards and will make it easier to find people and documents and to track WRAP activities. The new Web site should be on line by 2003.

Long-Term Planning

In its FY02 grant guidance to Regional Planning Organizations (RPOs), the EPA asks that the work plan be coupled with an updated description of what is anticipated to be the general work plan for several years. The description should provide an indication of the RPOs’ course of action, including its vision of the direction for the planning process, how it will develop partnerships and jointly determine this direction, how it will assess data needs, what tools it will need, and how it will work with other RPOs.

Much of the information requested above is provided in Sections III, IV, and IV of this document. The WRAP will work with other RPOs through the technical discussion groups facilitated by EPA, through regular participation in director-level calls and meetings, and as necessary on other issues (e.g., emission inventories and control strategies in border regions). The WRAP’s needs for new and improved data and tools are generally assessed within its forums and is refined through the annual work plan development process. Participation in inter-RPO discussion groups provides further opportunity to identify and refine these needs. Some specific long-term needs are identified in the preliminary long-term budget in AppendixB. This budget and the activities therein will be the subject of a WRAP work group to convene early next year to flesh out a more detailed technical work plan for §308 SIPs. An outline of this work plan was presented and discussed at the WESTAR technical conference in September 2002.

On a more general level, the WRAP’s planning process must accommodate a unique landscape of environmental, social, economic, and political issues. The WRAP region includes the vast majority of Class I areas, half the land mass of the United States (not including Alaska), a very large portion of publicly-owned lands, and numerous tribal jurisdictions (many with large land areas). It also emits a minority of total U.S. emissions, borders both Canada and Mexico, and receives pollution from Asia. Most WRAP members will not have to contend with ongoing ozone and particulate matter nonattainment issues. This simplifies air quality planning to some extent, but the lack of a clear threat to public health may detract some attention from the region’s air quality programs. Moreover, the WRAP must be sensitive to other regionally-important environmental issues, such as fire, drought, and endangered species. This presents a unique and challenging environment for long-term planning which is best addressed through a single, well-funded and well-organized institution at the appropriate political level. The WRAP, with the appropriate EPA financial support, provides such an institution, especially given its co-management structure shared between the Western Governors’ Association and the National Tribal Environmental Council. For example, WRAP uses the WGA-developed environmental management principles known as Enlibra ( Use of the Enlibra principles has helped garner support from western governors and other stakeholders as an example of how environmental issues should be addressed in the region. Such coordination is key regional haze planning in the west.

The WRAP’s long-term planning process must be prepared to deal with relevant events beyond its control, such as multi-pollutant legislation and the ramifications of legal challenges to the regional haze rule and other regulations. One way the WRAP can contend with these events is to have sufficient staffing to track the issues and to promote a constructive dialogue among its members.

In the long-term, the WRAP must continue to examine and develop innovative market-based approaches to achieving emission reductions. Examples include the expansion of the SO2 backstop market trading program to include additional states and/or tribes, and possibly additional pollutants and source sectors. Finally, the WRAP must continue its outreach activities and its efforts to incorporate new science as it becomes available.

Table 1. Major WRAP Products For Section 309 SIPs,

To Be Completed By The End of 2002.

  • Projections of visibility improvements for all Class I areas in the contiguous WRAP region resulting from §309 strategies.
  • A definition and policy on clean air corridors.
  • A model rule, draft MOU, and SO2 emission monitoring protocols for non-utility sources needed to implement the backstop emission trading program.
  • A demonstration that the backstop emissions trading program for SO2 will achieve greater reasonable progress than source-specific BART for the other ClassI areas, as defined in §309(g).
  • A final report on the WRAP mobile source inventory.
  • Determination of any areas in which mobile source emissions or road dust emissions significantly contribute to visibility impairment in any of the 16 Class I areas.
  • A final report on the WRAP fire emissions inventory.
  • An enhanced smoke management program.
  • Fire emission goals and tracking system.
  • A final report on recommended pollution prevention measures and emission and economic impacts
  • 1996 and 2018 base case air quality simulations.

Table 2. Miscellaneous WRAP Products For Section 309 SIPs,

To Be Completed in 2003.

  • A regional technical support document for implementation plans.
  • Stationary source NOx and PM report.
  • Specifications for an emission and allowance tracking system for the SO2 backstop emission trading program.
  • Facilitation of allowance allocation formulas and a policy on geographic enhancements.
  • Support for documenting the implementation status of regional and local mobile source control strategies recommended in the GCVTC final report.
  • Support for identifying and documenting state-specific pollution prevention goals and programs.
  • Support for documenting the implementation status of other recommendations in the GCVTC final report.

Table 3. New Projects And Extensions Of Existing Projects

Intended To Support §308 SIPs And The Longer-Term Needs Of §309 SIPs.

  • Identification of BART-eligible sources.
  • Updated emissions inventories mobile sources.
  • Updated and new emissions inventories for fire.
  • Development of representative communities for emission inventories in rural areas.
  • A “Tribal Emissions Inventory Software Solution” tool for use by tribes (and others), to facilitate development of accurate and consistent emissions inventories using a geographic information system as the framework
  • Creation of an emissions data management system to support tracking requirements for clean air corridors, the SO2 emission backstop trading program, fire emissions, and other programs as necessary.
  • Significant new work on the definition of dust (geogenic material) observed on IMPROVE PM10 filters, classification of natural and anthropogenic dust emissions, and technical investigations to better define the physical characteristics of dust aerosols.
  • Characterization of emission sources near Class I areas.
  • Outreach and development of an emission management plans for a gateway community.
  • Support for demonstration projects addressing existing non-road mobile sources.
  • Building regional capacity to develop and trade renewable energy credits.
  • Development of a common economic analysis framework and an efficient inhouse assessment capacity.
  • A major effort to characterize the “Causes of Haze” at each Class I area in the WRAP region using IMPROVE monitoring and associated meteorological data to derive source category impacts, seasonal variations, trends, contribution of natural sources, et cetera.
  • Extensive expansion of air quality modeling capabilities, including testing of new codes, development of emission and meteorological files for 2002, further model evaluation, improvements to the ammonia inventory, nesting of model grids, testing of plume-in-grid modules, implementation of process analysis techniques, and development of standardized post-processing tools.
  • Development of a WRAP-wide technical quality assurance management plan.

Table 4. Projects To Evaluate Haze And Develop A SIP For Alaska.

  • Representative community emissions inventories are planned for Alaskan villages, which have distinctly different activity patterns for visibility-impairing emissions.
  • Develop a meteorological model to cover a large portion of the land area of the state for simulating the effect of emissions regulated by the State of Alaska at 2 of the state’s 4 Class I areas; the areal extent of the meteorological model would capture most of the (human) population and a representative mix of emissions sources.
  • Emissions inventory work for fire, area, and stationary sources.

Table5. WRAP Budget for CY03.

Projects / CY03
Proposed
Market Trading Forum
Analysis of NOx and PM for Section 309 and 308 / 65,000
ATS/ETS Specifications / 50,000
Identify BART-Eligible Sources / 30,000
Fire Emissions Joint Forum
Wildland Emission Trade-Offs Review (Fire Emissions Tradeoff Model) / 30,000
Model Assessment/Sensitivity Runs / 50,000
Prepare SIP/TIP Technical Support Document Fire Emissions chapter / 10,000
Expand Ag Alternatives Report - more involvement of stakeholders / 100,000
Technical Guidance on ERT Use (supports annual emissions goal reporting) / 40,000
2002 Inventory of Wx, Rx, and WFU for wildland, rangeland, ag / 125,000
2018 Projections of Wx, Rx, and WFU for wildland, rangeland, ag / 50,000
Modeling to Assess de minimus Tracking Levels / 100,000
Addtl. Guidance on Policy for Categorizing Fire Emissions / 40,000
WRAP policy to coordinate regional ESMP implementation including workshop / 60,000
Guidance to support implementation of the Fire Tracking System (FTS) Policy / 25,000
Co-Sponsor National Fire Conference / 30,000
Air Pollution Prevention Forum
Tracking and Reporting RE and EE Implementation and Impacts of Legislation / 40,000
Develop Market Guidelines, Verification Protocols for Regional Credit Trading / 80,000
Technical Assistance to States/Tribes for SIPs/TIPs / 50,000
Energy Efficiency Screening Tool for State-Specific Impacts / 50,000
Mobile Sources Joint Forum
Draft Guidance for Promoting Non-Road Demonstration Projects / 20,000
Support Non-Road Demonstration Projects / 50,000
VMT/Energy Reduction Demonstration Projects and Guidance / 25,000
Sources In and Near Class I Areas Forum
Gateway Community Demonstration Project / 60,000
Economic Analysis Forum
Development of In-House Modeling Capabilities / 85,000
Air Quality Modeling Forum
Regional Technical Center (UCR) / 600,000
Alaska Modeling - Placeholder until further review by AQMF / 200,000
Emissions Forum
Improvements for NH3 / 45,000
Emission Inventory Data Base System - Development / User Access Capability / 122,400
Update On-Road and Non-Road Inventories with New Emissions Models / 40,000
Develop Representative Community EI's (Phase 1) - (incl. Alaska) / 175,000
Research & Development Forum / Dust Tasks
Followup Secondary Org Aerosols Analysis Work / 10,000
Stacked Filter Unit and Module D Data Analysis / 31,000
Ambient Monitoring and Reporting Forum
Establish and Maintain VIEWS Database (CSU) / 249,724
Establish and Maintain VIEWS Database -- CENRAP's 04 contribution / 50,000
Causes of Haze Report (DRI) -- 3 years / 225,000
Tech-Wide Projects
Quality Management Plan / 25,000
Geographic Data Display / 25,000
Air Managers Committee
State/Tribal Caucus Staff Support (WESTAR) -- Includes Travel / 117,400
STIP II Contractor Assistance / Program Enhancement / 161,476
Communications Committee
Web Site Administration (B. Bissey) / 30,000
Retool Web Site / 15,000
WRAP Sheet and Handout Material / 7,000
Presentation Material on WRAP / 8,000
Speaker's Bureau / 9,000
Support Forums and Committees / 5,500
Partner with Other Agencies/Programs to Widen Audience / 3,500
Travel and Project Management
Travel Reimbursed by WGA / 180,000
Conference Calls / 40,000
Meeting Expenses / 50,000
Other Expenses / 20,000
WGA Salaries and Benefits / 370,000
WGA Overhead / 240,000
Subtotals
Subtotal for Contractor Assistance / 3,420,000
Subtotal for Travel and Project Management / 900,000
Subtotal for NTEC / 305,000
GRAND TOTAL / 4,625,000

ES-1

Draft CY03 WRAP Work PlanOctober 22, 2002

Table 6. Long-Term Conceptual Schedule For WRAP Activities.*

Target Date / Technical Activity / Policy Activity / Target Date
2002 / Emissions inventory base year / Scoping workgroup on WRAP long-term work plan and activities / late 2002 – early 2003
January 2003 to September 2004 (21 months) / 1) Model upgrades/evaluation/testing new tool development (see Modeling Forum activity list for the RMC)
2) EI improvement work (see EF list) / Policy Forums begin to identify all likely control strategy options and regulatory framework for Regional Haze SIPs/TIPs / mid-2004
(18 months)
June 2004 / 2002 WRAP emissions inventories complete
October 2004 / Placeholder – EPA releases 2002 NEI (with one state review incorporated – WRAP to use as a filler)
March 2005
(9 months) / WRAP RMC completes emissions processing quality assurance, model input formatting, met modeling and provides updated base and projection year emissions files / Policy Forums sort control strategy options into regional and state/tribe, ranking the list for each of the 2 strategy groupings / end of 2005 (18 months)
September 2005
(6 months) / Base year and 2018 modeling completed – identifying source apportionment by jurisdiction for source categories
July 2006
(9 months) / 2018 regional control strategies’ modeling completed
early 2007 / Regional Technical Support Document complete / States and tribes prepare and submit SIPs/TIPs / 11-12/2007 (16 months)

* Assumes harmonized RH/PM2.5 SIP due date of 11-12/07, based on changes during the TEA-21 Congressional reauthorization by 9/03, and designations of PM2.5 attainment and nonattainment areas in late 2004.